MNT-14.1: Maintenance Personnel Without Appropriate Access

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Maintenance (MNT) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with MNT domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Maintenance-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Maintenance controls are primarily administrative in nature (e.g., policies & standards) to manage change control processes associated with maintenance operations.

Maintenance (MNT) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with MNT domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with MNT domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with MNT domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Maintenance-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ IT personnel, in conjunction with asset custodians, develop and maintain facilitate localized/regionalized procedures to conduct controlled and timely maintenance activities throughout the lifecycle of the Technology Asset, Application and/or Service (TAAS). ▪ Maintenance operations may be centralized for certain locations (e.g., datacenters) and decentralized for other locations, both in terms of change management and execution. ▪ Asset / process owners require maintenance personnel to obtain pre-approval and scheduling for non-local maintenance sessions. ▪ IT personnel, in conjunction with asset custodians, mitigate the risks associated with maintenance personnel who do not have appropriate access authorizations, clearances or formal access approvals are appropriately mitigated.

Maintenance (MNT) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with MNT domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with MNT domain capabilities (e.g., maintenance pans) are documented and maintained by process owners. ▪ A centralized Change Management Office (CMO), or similar function, is appropriately staffed and supported to implement and maintain MNT domain capabilities. ▪ Technical procedures (e.g., ITIL change enablement) are utilized along with change management governance capabilities to ensure successful, efficient and secure maintenance operations. ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with MNT domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to ensure the risks associated with maintenance personnel who do not have appropriate access authorizations, clearances or formal access approvals are appropriately mitigated.

Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.